The Business Council's comments on the safeguard mechanism rule and regulations are made from the perspective that Australia's policy response to the risks associated with climate change should be workable, at lowest possible cost, economically responsible, not make Australian industries noncompetitive, particularly if competitor nations do not take equivalent actions, and provide the foundations for a durable, long-term policy framework that is responsive to international negotiations.

The Business Council appreciates the consultation on the safeguard mechanism to date, and changes made to improve the operation of the safeguard mechanism as a result of this consultation. However, we are concerned that the short time available to consider the draft rule and regulations provides limited opportunities to identify potential unintended consequences as a result of drafting.

The government has made clear its intention that the Emissions Reduction Fund and safeguard mechanism are 'designed to allow businesses to continue ordinary operations without penalty'.

Noting the government's intentions, the Business Council sets out a number of recommends in this submission to the recently released Draft National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 and regulations.

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Submission to the Australian Consumer Law Review

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